F0835 F835: Administer the facility in a manner that enables it to use its resources effectively and efficiently.
D

Imposter RN Hired and Allowed to Function Without Proper Verification

Waters Of Memphis A Rehabilitation & Nursing CtrMemphis, Tennessee Survey Completed on 03-18-2026

Summary

Administration failed to ensure that nursing services were provided by qualified personnel when an unlicensed individual was hired and worked as an RN using another nurse’s Tennessee license. Facility policy titled “Abuse Program Policy” required pre-employment screening, including obtaining a copy of the state license for licensed positions and completing a criminal background check per state statute. The application for employment for the imposter nurse contained a scratched-out Social Security Number (SSN) with a different SSN written above that did not match the SSN on the I-9 form, and the birth date on the application also did not match the I-9. The background screening report showed an SSN and birth date that did not match the I-9 and included a note stating “UNABLE TO VALIDATE SSN.” A W-4 form contained an SSN that did not match the background check. The I-9 form listed the imposter’s legal first and last name, with a Social Security card and valid Tennessee driver’s license, but the birth date on the I-9 differed from the birth date on the background check. Review of the personnel file revealed no evidence that an abuse registry check was completed prior to hire, and there was no evidence that a license verification was done before the imposter nurse’s start date. Time cards showed the imposter worked multiple days in February and March as a Unit Manager. A later QuickConfirm license verification showed that the last name on the validated RN license did not match the imposter’s last name. Interviews with the DON, HR representative, and Administrator confirmed that the imposter was a walk-in applicant who did not provide a resume, that in-house HR was responsible for ordering background checks with corporate as backup, and that the imposter worked in the facility as a Unit Manager and was only separated as a voluntary termination for inability to uphold weekend schedule obligations. There was no evidence that the facility questioned the discrepancies in names, birth dates, or SSNs on the pre-employment documents, resulting in the employment of an unqualified person to render nursing services as an RN.

Penalty

No penalty information released
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The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.

Resources

Below are regulatory guidelines relevant to this citation:

See other F0835 citations
Failure to Protect a Known Elopement Risk
D
F0835 F835: Administer the facility in a manner that enables it to use its resources effectively and efficiently.
Short Summary

The NHA and DON failed to manage the facility effectively to protect a resident known to be at risk for elopement. A resident exited the assigned nursing unit unsupervised, and the report states this created an Immediate Jeopardy situation for one of fourteen residents documented as elopement risks. The NHA and DON confirmed the administrative failure during interview.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Ineffective Administration Affecting Falls, Staffing, Nutrition, Immunizations, and Abuse Prevention
F
F0835 F835: Administer the facility in a manner that enables it to use its resources effectively and efficiently.
Short Summary

Ineffective administration led to multiple failures in fall management, staffing, nutrition, immunization education, and abuse prevention. The facility did not follow fall interventions or complete accurate fall assessments and investigations, and two residents sustained serious injuries, including rib fractures and a thoracic burst fracture after an improper transfer. The report also cites inadequate RN coverage, insufficient staffing, missed dialysis transport, inaccurate documentation, falsified bathing records, failure to provide snacks and adaptive equipment, and abuse-related issues including verbal abuse and misappropriation of resident funds and property.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Timely Report Abuse and Neglect Allegations
E
F0835 F835: Administer the facility in a manner that enables it to use its resources effectively and efficiently.
Short Summary

Failure to Timely Report Abuse and Neglect Allegations: The facility failed to maintain an effective system for timely reporting allegations of abuse and neglect after a prior F609 citation for the same issue. Surveyors found nine late reports involving multiple residents, and staff and the administrator acknowledged ongoing difficulty tracking when reports were due, with most late reports occurring during the monitoring period after the earlier deficiency.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Protect Resident from Elopement
J
F0835 F835: Administer the facility in a manner that enables it to use its resources effectively and efficiently.
Short Summary

A resident with dementia and wandering tendencies was not protected from elopement after staff failed to follow instructions to place a Wander Guard and move him to the Secured Memory Unit. The resident was seen in the lobby, later could not be located, and was found miles from the facility after leaving unsupervised; the front entry door also lacked an operational Wander Guard system.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Ensure Supervision and Elopement Prevention
D
F0835 F835: Administer the facility in a manner that enables it to use its resources effectively and efficiently.
Short Summary

Failure to Ensure Supervision and Elopement Prevention: The facility failed to consistently supervise and maintain safety interventions to prevent elopement for residents. Review of records, job descriptions, and staff interviews showed the NHA and DON did not effectively manage the facility to ensure proper supervision and elopement prevention interventions were implemented, and they failed to fulfill their essential duties to ensure federal and state guidelines and regulations were followed.

Inspection fine: $14,385
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The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Unqualified Social Service Director Hired
F
F0835 F835: Administer the facility in a manner that enables it to use its resources effectively and efficiently.
Short Summary

Unqualified Social Service Director Hired: The facility failed to ensure the Social Service Director met the stated qualification of a bachelor's degree and 1 year of social services experience. The Administrator stated the current SSD was still in school and had not completed her degree, while a behavioral health director with a degree only helped with social services at times and was not the SSD. The job description and facility policy did not align with current regulatory requirements, and the facility census was 182 residents.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
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